New Device Inspection Protocol Analyzed
Three Hogan Lovells attorneys say FDA’s new medical device inspection protocol that aligns with the new Quality Management System Regulation will require device manufacturers to prepare for a significant operational and cultural transformation for undergoing, addressing, and responding to inspections and remote regulatory assessments. Writing in an online post, the attorneys say manufacturers will be expected to not only demonstrate procedural compliance with QMS regulations, but also confirm affirmatively with evidence the existence of a robust, self-correcting quality culture.
The post recommends that manufacturers evaluate whether their current systems (1) demonstrate closed-loop use of risk information, (2) reflect genuine management involvement, and (3) can withstand FDA review of internal audits, supplier oversight, and life-cycle data integration. “Early preparation will be critical to avoid inspection surprises under the new compliance program (CP),” they conclude.
The new CP 7382.850 marks a significant shift in FDA inspection methodology, the attorneys say. It establishes an expansive model for assessing product and process risks, all centered around risk to patients and users. The new program organizes inspection emphasis into six Quality Management System areas (change control; design and development; management oversight; measurement, analysis, and improvement; outsourcing and purchasing; and production and service provision) and four categories of Other Applicable FDA Requirements (medical device reporting, corrections and removals, tracking, and unique device identification).